Easy to Read Summary: Edwards v. Shelby County

The Case

A case citation talks about the case and where to find the court decision. To learn more, read: How to Find the Court Case and What Each Part Means in the Case Citation.

What This Case Is About

This case is about a woman named Rebecca Edwards who worked for a health department in Tennessee. She had trouble seeing at night (called “night blindness”) and had asthma. When she asked her bosses for help with these problems, they fired her. She said this was against the law, and she took them to court.

What is the Americans with Disabilities Act (ADA)?

The Americans with Disabilities Act (ADA) is a law that protects people with disabilities. The law says:

• Bosses cannot treat workers badly just because they have a disability.
• Workers can ask for reasonable help to do their jobs.
• Bosses cannot fire or punish workers for asking for this help.

What Happened to Rebecca Edwards?

Her Job

• Rebecca started working for the Shelby County Health Department in July 2020.
• Her first job was tracing COVID-19 contacts.
• Five months later, she got a promotion to Environmentalist Inspector.
• This new job sometimes required driving at night.

Her Night Blindness

Rebecca could not see well at night. This is what happened to her eyes:

• Bright headlights and streetlights made blurry circles (called halos) in her vision.
• She could not see lane lines or road signs clearly.
• She had trouble judging distances.
• After seeing bright lights, she could not focus her eyes for a while.

To stay safe, Rebecca drove slowly at night. Sometimes she followed police cars or coworkers when she had to drive.

Her New Assignment

In August 2021, Rebecca was moved to a new team. She had to deliver food and groceries to people who had COVID and were staying at an Econo Lodge motel.

Rebecca thought the Econo Lodge was dangerous, especially at night. She saw scary things happen there:

• Someone left drugs in a room.
• A man who said he was a bounty hunter asked her to knock on a door for him.

She told her boss about these safety problems.

Her Asthma

Rebecca also had asthma. Asthma makes it hard to breathe. She usually took medicine that kept it under control. But sometimes her asthma got really bad.

In September 2021, Rebecca could not get her medicine for a little while. Her asthma got very bad. She could barely breathe, could not sleep, and could hardly walk from her bedroom to the bathroom.

At 4:30 AM on September 15, 2021, she called her boss and left a message saying she was too sick to work. The county’s rule said workers only needed to call 30 minutes before their shift started, so she called way earlier than required.

Her boss called back at 7:30 AM and told her to come to work anyway because it was “too late” to find someone else. Even though Rebecca was still having trouble breathing, she went to work.

The Night Shift Problem

On October 4, 2021, Rebecca’s boss told her she had to work a shift from 3:00 PM to 11:00 PM at the Econo Lodge—all by herself. This meant she would have to drive home in the dark.

Rebecca told her boss:

• She had night blindness.
• She could not drive safely at night.
• She was scared to work alone at the motel late at night.

Her boss said Rebecca had driven at night before for work. Rebecca explained that she rarely drove at night, and when she did, she usually had police or coworkers with her.

What Happened Next

The next day (October 5, 2021), Rebecca started her new night shift. At 4:07 PM, she sent an email to her boss telling them again about the dangerous things at the motel and that it was not safe for her to work there alone at night.

What Rebecca did not know was that earlier that same day, her boss had asked to remove her from the team. Her boss was told to write down complaints about Rebecca. The boss wrote reports saying Rebecca was sometimes late, sometimes refused to go to the motel, left early, and did not do much work.

Rebecca Gets Fired

On October 6, 2021, Rebecca’s schedule changed again—this time to 10:30 AM to 7:30 PM. She found out about the change at 10:45 AM, after the new shift had already started. She got to work after 1:00 PM and worked until 7:00 PM.

A few days later, the Human Resources department said Rebecca should be fired. On October 11, 2021, she was fired. The reasons given were “not following orders,” “attendance problems,” and “lying.”

The form that explained why she was fired said she had never been in trouble at work before. It did not mention her night blindness or her request to change her schedule.

1. Is night blindness a disability under the ADA?
2. Did Shelby County retaliate against Ms. Edwards by firing her because she asked for a reasonable accommodation related to her night blindness?
3. Is Ms. Edwards’ asthma, even though it only happens sometimes, a disability under the ADA, and did Shelby County fail to reasonably accommodate that asthma when she was having a serious episode?

Rebecca Goes to Court

Rebecca filed a complaint with the Tennessee Human Rights Commission, which was forwarded to the Equal Employment Opportunity Commission (EEOC). These are agencies that handle job discrimination cases. Then, she sued the county in court. She said:

1. The county discriminated against her because of her night blindness.
2. The county punished her for asking for help with her night blindness.
3. The county did not help her when her asthma got bad.

A jury (a group of regular people who decide court cases) listened to everyone’s side of the story. They agreed with Rebecca on all three complaints. The county did not think this was fair, so they appealed to a higher court called the Sixth Circuit Court of Appeals.

The Three Big Questions the Court Had to Answer

Question 1: Is night blindness a disability under the ADA?

What the County Said:

The county argued that night blindness is not a real disability under the law. They said:

• Night blindness is not the type of problem the ADA covers.
• Driving at night is not a “major life activity” (important daily thing people do).
• Rebecca drove at night sometimes, including for work, so she was not really limited by it.

What the Court Decided:

The court looked at what the ADA says. A disability is when someone has a physical or mental impairment that makes it much harder for them to do important daily activities compared to most people.

The court said the problem was not about driving—it was about seeing. Seeing is definitely a major life activity. Night driving is just one of many things people do using their ability to see.

The court looked at how Rebecca’s night blindness affected her:

• She had trouble seeing traffic in her mirrors.
• She could not read road signs and exits well.
• Bright headlights made blurry circles (halos) in her vision.
• After seeing bright lights, she had trouble seeing anything—even reading mail or a menu.

The court said that even though Rebecca could still drive at night, it was much harder and more dangerous for her than for most people. That is enough to make it a disability.

Answer: Yes, Rebecca’s night blindness is a disability under the ADA.

Question 2: Did the County punish Rebecca for asking for help?

What the County Said:

The county said Rebecca was not really asking for help because of her disability. They said she was just scared of crime at the motel. They pointed to her email on October 5, 2021, which talked about criminal activity but did not mention her night blindness.

What the Court Decided:

The court said you cannot just look at one email. You must look at the whole story.

The day before that email (October 4, 2021), Rebecca told her supervisor directly about her night blindness and said she could not drive safely at night.

The court also noticed the timing:

• Rebecca asked for a schedule change because of her night blindness.
• Within a few days, her boss started writing complaints about her.
• The Human Resources department was asked about firing her.
• She was fired soon after.

The form explaining why she was fired did not mention anything about her disability complaints.

The court said this was enough evidence that the county punished Rebecca for asking for help with her disability.

Answer: Yes, the county retaliated against (punished) Rebecca for asking for a reasonable accommodation.

Question 3: Is asthma that comes and goes still a disability? Did the county fail to help Rebecca with her asthma?

What the County Said:

The county argued that Rebecca’s asthma was not a disability because:

• It was usually controlled with medicine.
• It only got bad sometimes.
• The serious incident on September 15, 2021, only happened because she ran out of medicine.

What the Court Decided:

The court disagreed for two important reasons:

First: The ADA says that conditions that come and go can still be disabilities. When deciding if something is a disability, courts should think about how bad it is when it is happening—not how well medicine controls it.

Second: When Rebecca’s asthma flared up, it was very serious.

• She had trouble breathing.
• She could not sleep.
• She could barely walk from her bedroom to the bathroom.

The court compared Rebecca’s case to another case from 2008 in the Sixth Circuit decision Andrews v. Tri Star Sports and Entertainment Group. In the older case, the person with asthma lived a very active life and did intense exercise. That person could not give specific examples of how asthma made basic activities harder. Rebecca’s case was different—she gave clear examples of how her asthma made breathing, walking, and sleeping very difficult when it flared up. [You can view this older case online at: Andrews v. Tri Star Sports and Entertainment Group.]

About the failure to help: On September 15, 2021, Rebecca called her boss hours before her shift (much earlier than required by company rules). She explained she could not breathe well and had not slept. Instead of letting her stay home, her boss told her to come to work anyway.

The court said the county should have let Rebecca stay home that day. The county did not show any good reason why they could not do this.

Answer: Yes, Rebecca’s asthma is a disability. Yes, the county failed to help her when she needed it.

Final Decision

The Sixth Circuit Court of Appeals agreed with the jury and ruled in Rebecca’s favor on all three complaints:

1. Night blindness is a disability when it makes seeing and driving at night much harder and more dangerous than for most people.
2. The county punished Rebecca for asking for help with her night blindness.

Asthma can be a disability even if it comes and goes, if it makes basic activities like breathing, walking, and sleeping much harder when it happens. The county should have let Rebecca stay home when she was having a serious asthma attack.

How to Find the Court Case

The full listing of a court case is called a citation. This citation talks about the case and where to find the court decision. Below are a table and a list of what each part means in this court case citation.

Court Case Citation   

The Parts of the Court Case Citation

• Plaintiff: The last name of the person or name of the group who is bringing the case to court. In this case, the plaintiff is Edwards.
  • In cases where there is more than one person, the first person listed, sometimes known as the “lead” plaintiff.
• Versus: The short way to write “versus” is a lowercase letter v with a period (v.). This separates the “parties” of the case, the name of the plaintiff from the name of the defendant.
• Defendant: The name of the person or group who the case is being brought against. In this case, Shelby County, Tennessee (Shelby Cnty., Tenn).
  • In cases where there is more than one defendant, the name listed in the citation is the first defendant named in the lawsuit.
• Docket: The case number (No.) set by the court. In this case, No. 24-5730.
• Volume: This is the bound volume where the case can be found. In this case, the dash means the volume is not yet assigned.
• Reporter: This is the source where the case is found. In this case, the fourth series of the Federal Reporter (F. 4th).
• Page: This is the first page of the volume where the case is found. In this case, the dashes mean the page is not yet assigned.
• Court: The court that heard the case. In this case, the United States Sixth Circuit Court of Appeals (6th Circuit).
• Year: The year or date the case was decided by the court. In this case, 2025.

Disclaimer

These materials do not constitute legal advice and should not be relied upon in any individual case. Please consult an attorney licensed in your state for legal advice and/or representation. These materials were prepared by the legal research staff of the Burton Blatt Institute (BBI) at Syracuse University in partnership with the Southeast ADA Center to highlight legal and policy developments relevant to civil rights protections and the impact of court decisions in the Southeast Region under the Americans with Disabilities Act (ADA). These materials are based on federal disability rights laws and court decisions in effect at the time of publication. Federal and state disability rights law can change at any time.  In addition, state and local laws and regulations may provide different or additional protections. Materials are intended solely as informal guidance, and are neither a determination of your legal rights nor responsibilities under the ADA or other federal, state, and local laws, nor binding on any agency with enforcement responsibility under the ADA. The accuracy of any information contained herein is not warranted. Any links to external websites are provided as a courtesy and are not intended to nor do they constitute an endorsement of the linked materials.